A corporation falls to qualify as an S corporation solely because its Form 2553, Election by a Small Business Corporation (Under section 1362 of the Internal Revenue Code), was not filed timely; the corporation intended to be an S corporation; the corporation and its shareholders reported their income consistent with S status for the tax year the election should have been made and for every subsequent year; at least six months had elapsed since the date on which the corporation filed its tax return oil Form 1120-S, U.

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